G.R. No. 76742 - People vs. De Guzman y Enriquez

On July 19, 2011, Leilani Lim Go filed a petition for declaration of nullity of her marriage with Hendrick N. Go under Article 36 of the Family Code, docketed as Civil Case No. R-PSY-14-17782-CV before RTC Branch 113, Pasay City.
The RTC granted the petition on May 3, 2018; the CA reversed on December 17, 2020 and denied reconsideration on November 3, 2021.

Leilani and Hendrick met in 1996–1997, courted in 1998, and married on August 7, 1999 at St. Augustine Church, Intramuros, Manila; they had two surviving children, Lance Harvey and Heiley Louise, and lost a third pregnancy in 2007.
They lived with Hendrick’s parents; tensions arose from in-law comments, Hendrick’s alleged infidelity, differing expectations on intimacy and child-rearing, and Hendrick’s contentment with a small income.

Leilani’s Testimony: chronic lack of affection, Hendrick’s continued communication with ex-girlfriend “Kristine,” financial neglect, infrequent sexual relations, emotional indifference, and eventual physical separation in 2013.
Jennel See’s Testimony: corroborated Leilani’s accounts of Hendrick’s emotional distance, infidelity, and the couple’s discord observed during visits and trips.
Clinical Psychologist’s Evaluation (Dr. Nedy L. Tayag): diagnosed Leilani with Passive Aggressive Personality Disorder (with Narcissistic features) and Hendrick with Avoidant Personality Disorder (with Antisocial features); found both conditions permanent, grave, and incurable, thus causing marital incapacity.
Hendrick’s and His Father’s Testimonies: disclaimed infidelity, asserted ongoing love, parental support, and financial care; Hendrick admitted thoughtless spending but denied personality dysfunction.

RTC Decision (May 3, 2018): declared the marriage void ab initio, citing clear and convincing proof of both spouses’ psychological incapacity.
CA Decision (December 17, 2020): reversed the RTC, holding evidence insufficient to prove Hendrick’s psychological incapacity; deemed the psychologist’s findings one-sided and noted lack of personal examination.
CA Resolution (November 3, 2021): denied Leilani’s motion for reconsideration.

Whether the marriage of Leilani and Hendrick is void ab initio under Article 36 of the Family Code due to psychological incapacity.

Whether psychological incapacity, as re-conceptualized by the Supreme Court (Tan-Andal and Laroco), was clearly and convincingly established.
Whether mutual incompatibility and antagonism between the spouses satisfy the elements of gravity, juridical antecedence, and incurability.